Case Digest: PEOPLE OF THE PHILIPPINES v. BERNARDO SARA 417 SCRA 431 (2003)

PEOPLE OF THE PHILIPPINES v. BERNARDO SARA 417 SCRA 431 (2003)

It is unnatural for aggrieved relatives to falsely accuse someone other than the actual culprit, for their natural interest in securing the conviction of the guilty would deter them from implicating any other. Paterno Morcillo was about to transfer his Carabao in front of their house in Cabatuan, Iloilo when gunshots were fired against him which caused his death. Morcillo‘s two sons, Benjamin and Felipe saw that the perpetrator was Bernardo Sara and Efren Robles. Upon investigation, the police found Berning and Efren to be positive for gunpowder residue but they denied the allegation. The Regional Trial Court (RTC) acquitted Efren and convicted Berning guilty of murder. The Court of Appeals affirmed the decision of the RTC.

ISSUE:

Whether or not the evidence of the prosecution established the guilt of Bernardo Sara beyond reasonable doubt

HELD:

Both Felipe and Benjamin testified that there was ample illumination from the moon to enable them to see the face of there father‘s assailant. There was thus no possibility for both witnesses to be mistaken in identifying their father‘s assailant, especially considering that they have known Bernardo Sara, their neighbor, for a long time. There being no indication that Felipe and Benjamin were actuated by any improper motive to falsely testify against appellant, their relationship with the victim notwithstanding, there is no reason to doubt the veracity of their testimonies. Relationship could in fact even strengthen the witnesses‘ credibility; it being unnatural for aggrieved relatives to falsely accuse someone other than the actual culprit, for their natural interest in securing the conviction of the guilty would deter them from implicating any other.